Pangasinan Transportation Co. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Cecilio Gatdula, employed as a driver by Pangasinan Transportation Co., Inc. from January 4, 1950, endured long hours and exposure to dusty conditions on his routes. He also assisted with loading and unloading baggage. In June 1953, Gatdula was involved in an accident, sustained injuries, and was hospitalized. After recovering and returning to work in January 1954, he began experiencing chest and back pains, and headaches. By January 1955, he was diagnosed with acute bronchitis, and a month later, with moderate pulmonary tuberculosis, which subsequently became chronic and bilateral. Procedural History: Gatdula filed his notice of sickness and claim for compensation on September 2, 1957. The claim was initially heard by Hearing Officer Liberato C. Delizo of Regional Office No. 1, Dagupan City, who rendered a decision ordering the petitioner to pay compensation, provide medical treatment, and pay costs to the Workmen's Compensation Fund. The respondent Workmen's Compensation Commission affirmed this decision with modifications and denied the petitioner's motion for reconsideration. The Petition: Pangasinan Transportation Co., Inc. petitions this Court for a reversal of the Workmen's Compensation Commission's decision. The petitioner argues that the claim is barred due to Gatdula's failure to file the notice of sickness and claim within the statutory 60-day period. Additionally, they contend that the hearing officer lacked jurisdiction and that Gatdula's illness was not caused by, traceable to, or aggravated by his employment. The petitioner seeks to overturn the commission's findings and order.
Issue(s)
Whether the claim for compensation is barred by the claimant's failure to file the notice of sickness and claim within the prescribed period. Whether the hearing officer had jurisdiction to hear the case. Whether the claimant's pulmonary tuberculosis was caused by, traceable to, or aggravated by the nature of his employment.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, ordering the petitioner to pay compensation and medical expenses to the claimant.
Ratio Decidendi
On the issue of late filing of notice and claim: The Court held that the delay in filing the notice of sickness and claim for compensation, even if beyond two years from discovery of the disease, was excused. This was because the employer had actual knowledge of the claimant's bronchitis, which subsequently developed into pulmonary tuberculosis, and the claimant was laid off due to this affliction. Section 27 of the Workmen's Compensation Act, as amended, provides that failure or delay in giving notice shall not be a bar if the employer had knowledge of the accident or did not suffer by such delay or failure. The employer's actual knowledge of the claimant's condition satisfied this requirement, thereby excusing the delay in formal notification. On the issue of jurisdiction: The Court reiterated the settled doctrine that Reorganization Plan No. 20-A, insofar as it conferred judicial power to Regional Offices over cases not falling under the Workmen's Compensation Law, was invalid. However, it clarified that regional offices created under Reorganization Plan No. 20-A in the Department of Labor partake of the nature of referees that the Workmen's Compensation Commission could appoint and clothe with jurisdiction to hear and decide claims falling under the Workmen's Compensation Law. Therefore, the hearing officer had jurisdiction over the case, and their decisions on such claims were valid and binding, as supported by the ruling in La Mallorca and Pampanga Bus Company vs. Ramos, et al.. On the issue of causation and aggravation of illness: The Court upheld the Commission's factual finding that the rough and dusty condition of the routes, the physical exertion from lifting baggage, and the long working hours were precipitating factors and the producing cause of the aggravation of the claimant's pre-existing pulmonary tuberculosis. The Court emphasized that the employer failed to rebut the presumption in favor of the working man, as established in Naira vs. Workmen's Compensation Commission, et al.. The presumption is that an injury or death supervening in the course of employment is compensable unless the employer clearly establishes that it was not caused or aggravated by the employment. The company's theory that the claimant infected his wife was not given weight, especially since medical testimony indicated a strong probability that the claimant might have infected his wife instead.
Main Doctrine
The employer's actual knowledge of the claimant's illness, even if the notice of claim is filed beyond the statutory period, excuses the delay. Furthermore, the nature of the employment, characterized by rough and dusty routes, physical exertion from loading/unloading, and long driving hours, can be the precipitating factor and producing cause of the aggravation of a pre-existing pulmonary tuberculosis, making the illness compensable under the Workmen's Compensation Act.